OSHA Inspection: SANDVIK STEEL CO

Issued

Jul 23, 1991

Abate by

Oct 21, 1991

Penalty

Initial $1,500 · Current $750 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
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The employer did not furnish employment and a place of employment
which were free from recognized hazards that were causing or likely
to cause death or serious physical harm to employees in that employees
were required to perform tasks involving repetitive motions resulting
in stresses that had caused, were causing, or were likely to cause
cumulative trauma disorders:
(a)  Wire Draw Department - employees threading wire
draw operations and using hand cutters to cut wire,
the evaluation of this task indicates that employees
are exposed to a hazard which is causing or likely
to cause musculoskeletal disorders.  The employer
did not implement an effective control strategy to
reduce or eliminate such disorders.  The injury and
illness records for 1988 and 1989 documented a pattern
of repetitive motion injuries.
Among other methods, one feasible and acceptable
abatement method to correct this hazard is the
implementation of an ergonomics management program
consisting of the following four elements.
(1)  Worksite analysis to recognize and identify
existing manual lifting hazards in the
workplace.  This anaysis should include
development and use of an ergonomic checklist
and employee questionnaire.  Periodic surveys
of the worksite shall be conducted at least
annually to evaluate work practices and
engineering controls.  Employee participation
in the ergonomic program should be encouraged
through a mechanism such as a safety committee.
(2)  Medical management which includes accurate
recordkeeping of manual lifting injuries.  The
program should address recognition, evaluation,
treatment and referral of lifting cases.
Systematic worksite review by the medical team
should also be included in the program.
(3)  Training and education for exposed employees,
including methods to evaluate the effectiveness
of the training.  Re-training should be done
annually, or as operations change.  Training
should address hazards associated with the job,
the risks of manual material handling, and how
to prevent lifting injuries.  A supervisor's
training program should also be implemented to
allow recognition of manual lifting hazards,
and to reinforce the employer's ergonomic
program.
(4)  Hazard prevention and control which includes
engineering, work practices and administrative
controls:
(a)  Administrative controls are implemented
which reduce the duration, frequency, and
severity of exposure to manual lifting
hazards.  These controls may include job
rotation, reduction of repetitions, multiple
person lifts, and preventative maintenance
of related equipment.
(b)  Work practice controls are implemented which
include proper work techniques, new employee
conditioning, proper placement of loads,
and reduction of weight lifted.
Examples of work practice controls
applicable to this workplace include:
(i)    Insure the use of proper wire
cutting tools for the diameter
of wire being cut;
(ii)   Good cutting tool care, including
inspection of tools to insure
sharpness;  and
(iii)  Adequate number of personnel
available during threading
procedure.
(c)  Engineering controls are designed by a
qualified ergonomist and may include work
station redesign, tool and handle redesign,
and use of mechanical lifting aids.  The
goal of this program should be to make the
job fit the person.
Examples of engineering controls applicable
in this workplace include:
(i)    Provide wire cutting stations
at commonly used cutting points
to hold wire and inhibit whipping.
This should assist employees in the
use of two hand wire cutters for
heavier diameter wire.
(ii)   Evaluate cutting tool design.  Provide
a variety of tool size and design to
achieve proper fit and reduce ergonomic
risk.
ABATEMENT SCHEDULE
Step 1 - Implementation of an ergonomics program for worksite analysis,
medical management, and training and education, as detailed in
items 1-3, above.
Step 2 - Submit to the Area Director a written, detailed plan of abatement
outlining a schedule for the implementation of the administrative,
work practice and engineering controls as detailed in items 4(a)
- 4(c).
ALL PROPOSED CONTROL MEASURES SHALL BE APPROVED FOR EACH
PARTICULAR USE BY A PERSON TRAINED IN THE EVALUATION OF WORKPLACE
CONDITIONS WHICH CAUSE CUMULATIVE TRAUMA DISORDERS.  SIXTY (60)
DAY PROGRESS REPORTS ARE REQUIRED DURING THE ABATEMENT PERIOD.
Step 3 - Implementation of administrative, work practice and engineering
controls as described in items 4(a) - 4(c), above.